In what circumstances will a carjacker be found guilty of assault under section 654 of the California Highway Traffic Code for carjacking?

In this case, defendant's intent is clearly evidenced by his threats to physically harm the victim if the victim did not comply with his demand for the keys, and there is no evidence in the record of any objective other than completion of the carjacking. The People cite People v. Nguyen (1988) 204 Cal.App.3d 181, 190-191, for the proposition that "gratuitous violence against a helpless and unresisting victim ... has traditionally been viewed as not 'incidental' to robbery for purposes of ... section 654." We find the decision inapt, however.